IR 05000289/1992022

Insp Repts 50-289/92-22 & 50-320/92-16 on 921208-930118.No Violations Noted.Major Areas Inspected:Plant Operations, Maint,Radiological Controls,Security & Engineering & Technical Support Activities Re Plant Safety

ML20128G594
Person / Time
Site:	Three Mile Island
Issue date:	02/02/1993
From:	Rogge J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20128G591	List: IR 05000289/1992022 ML20128G589
References
50-289-92-22, 50-320-92-16, NUDOCS 9302160053
Download: ML20128G594 (11)

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U. S. NUCLEAR REGULATORY COMMISSION REGION 1 Report No Docket No License No DPR-50 DPR-73

Licensee: GPU Nuclear Corporation -

P.O. Box 480 Middletown, PA 17057 Facility: Three Mile Island Station, Units 1 and 2 Location: Middletown, Pennsylvania inspection Period: December 8,1992 - January 18, 1993 Inspectors: Francis 1. Young, Senior Resident inspector David P. Beaulieu, Resident Inspector John P. Segala, Resident Intern Approved by: N M8/'fLT

[fohn F. Rogge,6fif Date '

Reactor Projects Section No. 4B Inspectitu Summary The NRC Staff conducted safety inspections 'of Unit 1 power operations and Unit 2 cleanup activities. The inspectors reviewed plant operations, maintenance, radiological controls, security, and engineering and technical support activities as they related to plant safet Results An overview of inspection results is in the executive summary, j ..

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9302160053 930204 PDR ADOCK 05000289 G PDR

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I SUMMARY f Report Nos. 50-289/92-22 & 50-320/92-16 Plant Operations The inspector found that shift turnovers were comprehensive, accurate, and adequately reflected plant activities and status. Control room operators effectively monitored plant operating conditions and made necessary adjustments. Housekeeping was satisfactory, Overall, the licensee conducted Unit 1 plant operations in a safe manne The Unit-2 accident generated water evaporator continues to operate and approximately 1,453,000 gallons of AGW had been varx>rized to atmosphere at the close of the inspection perio Rndiologi. cal Controls -

During each Auxiliary Building tour the inspector paid particular attention to ensure radiological surveys were current and that proper warning signs were posted. The inspector noted no discrepancies and concluded that overall radiological controls were goo The licensee determined that a 204.7 pC uranium source had not been leak tested. Technical Specifications require scaled sources to be leak tested. The licensee is evaluating whether or not the source is by definition a sealed source to which the leak test requirement applie This item is unresolved pending further revie Maintenance and Surveillance While returning the flow recorder FR-146 (total station flow to the river) setpoint to normal following the release of the 'A' waste evaporator condensate storage tank to the mechanical draft cooling tower, the licensee found that the setpoint was set low at 9,000 gpm versus the ,

release permit required setpoint of 27,000 gpm. This incident was considered to be an isolated case and the licensee's corrective actions are adequate to prevent recurrenc The Fuel Handling Building ventilation was operated without placing the effluent radiation monitor in service as required by procedure. This item is unresolved pending completion of the licensee's revie The inspector closed an item concerning the failure of the licensee to inspect scaffolding to ensure the scaffolding will not endanger safety related equipment. The licensee corrective actions were adequate to prevent recurrenc Safety Assessment anLOuality Verification The inspector reviewed all TMI LERs that were submitted in 1992, to verify that the details of the events were clearly reported, including the accuracy of the description of cause and -

the adequacy of the corrective action. The inspector concluded all 1992 LERs were satisfactor Security The inspector concluded that the upgrades to the secondary alarm station that were completed during the inspection period were a good enhancement to plant securit iii

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DETAILS - SUMMARY OF FACILITY' ACTIVITIES Licensee Activities Unit I remained at 100% power throughout the inspection perio The Accident Generated Water (AGW) evaporator continued to. vaporize AGW'to the atmosphere and at the close of the inspection period approximately 1,453,000 gallons had been vaporized overall to dat .2 NRC Staff Activities This inspection assessed the adequacy of licensee activities for reactor safety, safeguards, and radiation protection. The i spectors made this assessment by reviewing information on a '

sampling basis. The inspectors obtained information through actual observation of licensee activities, interviews with licensee personnel, and documentation review The inspectors observed licensee activities during both normal and backshift hours: 1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of direct inspection were conducted on backshift and 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> were conducted on deep '

backshift. The times of backshift hours were adjusted weekly to assure randomness, PLANT OPERATIONS (71707)

2.1 . Operational Snfety Verification i i

inc nspectors observed overall plant operation and verified that the licensee operated the plant safely and in accordance with procedures and regulatory requirements. The inspectors conducted regular tours of the following plant areas:

--Control Room --Auxiliary Building-

--Switch Gear Areas -Turbine Building -

--Access Control Points -Intake Structure

--Protected Area Ferce Line --Intermediate Building

--Fuel Handling Building . --Diesel Generator Building-The inspectors observed plant conditions through control room tours to verify proper-alignment of engineered safety features; to verify that operator response to alarm conditions -

was in accordance with plant operating procedures; to verify compliance with Technical Specifications, including implementation of appropriate action statements for equipment out :

of service; and to review logs and records to determine if entries were accurate and identified'

equipment status or deficiencies. The:e records included operating logs, turnover sheets, and _

system safety tag The inspector conducted detailed walkdowns of accessible areas to inspect major components-and' systems for leakage, proper alignment, proper lubrication, proper cooling-water supply, .

and any: general condition that might prevent fulfillment of their safety function. The

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inspector observed plant housekeeping controls including control and storage of flammable material and other potential safety hazard The inspector found that shift turnovers were comprehensive, accurate, and adequately reflected plant activities and status. Control room operators effectively monitored plant operating conditions and made necessary adjustments. Housekeeping was satisfactory. The inspector concluded that the licensee conducted overall plant operations in a safe and conservative manne .0 EVAPORATION OF TMI UNIT 2 ACCIDENT GENERATED WATER (71707)

The inspectors observed overall evaporator operation and verified that the evaporator was operated in accordance with licensee procedures and regulatory requirements. At the close of the inspection period, approximately 1,453,000 gallons of the 2.3 million gallons of AGW had been evaporated. The inspectors identified no conditions that were adverse to safety or contrary to regulatory requirement .0 RADIOLOGICAL CONTROlE (71707) Routine Radiological Controls During entry into and exit from radiologically controlled areas, the inspectors verified that proper warning signs were posted, personnel entering were wearing proper dosimetry, personnel and material leaving were properly monitored for radioactive contamination, and monitoring instruments were functional and in calibration. The inspectors also reviewed extended Radiation Work Permits (RWPs) and survey status boards to verify that they were current and accurate. The inspectors observed activities in radiologically controlled areas and verified that personnel were complying with the requirements of applicable RWPs and that workers were aware or tie radiological conditions in the are During each Auxiliary Building tour tne inspector paid particular attention to ensure radiological surveys were current and that proper warning signs were posted. The inspector noted no discrepancies and concluded that overall radiological controls were goo .2 Missed Radionctive Source Leak Test (URI, 50-289/92-22-01)

On January 4,1993, the licensee performed a review of the TMI radioactive source inventory database and determined that source # 200, a depleted uranium slab with an activity of 204.7 pC of U-238, was improperly designated as not requiring a source leak test.-

The source is a plastic coated alloy metal slab (1/8" x 4" x 4") with uranium as one of the composite materials. Technical Specification 4.13.1, " Radioactive Material Sources Surveillance," requires all sealed sources with an alpha activity greater than 5 pC to be leak tested at intervals not to exceed six months. The leak test of this source was last performed q on February 21,1989. On January 4,1993, after discovery of the missed surveillance, the l licensee performed a leak test on the source with satisfactory result i

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The licensee reviewed the entire database and surveillance records and detennined that the other 60 sources requiti ng leak testing had received their surveillance. The licensee determined that the root cause of the event was attributed to personnel error in maintaining the source inventory database correctly. The licensee's initial corrective actions included the initiation of a special audit performed by the Quality Assurance Department. Further corrective actions will be determined based on audit findings.

The inspector reviewed the incident with Radiological Engineering management. The inspector determined that this event had minor safety significance because the source satisfactorily passed the leak test and this metal slab is not likely to leak uranium.

At the end of the inspection period the licensee was reevaluating whether or not source #200 is by definition a sealed source requiring the leak test. The issue will remain unresolved pending further review by the inspector and licensee. The inspector will also evaluate whether there is a programmatic weakness in the overall control of radioactive sources because of recent incidents of misplaced sources as documented in NRC Report No. 50-289/92-16 (50-289/92-22-01). MAINTENANCE AND SURVEILLANCE (61726,62703,71707,92702) Maintenance Observntions The inspector reviewed selected maintenance activities to assure that: the activity did not violate Technical Specification Limiting Conditions for Operation and that redundant components were operable; required approvals and releases had been obtained prior to commencing work; procedures used for the task were adequate and work was within the skills of the trade; maintenance technicians were properly qualified; radiological and fire preventive controls were adequate; and equipment was properly tested and returned to servic Maintenance activities reviewed included:

• Job Order No. 056439, " Brass Chip Found on NR-P-1B Packing Leakoff,"

was inspected on January 12, 199 * Preventive Maintenance Precc&re (PMP) E-28, " Westinghouse DAP Magnetic Air Circuit Breaker Inspection and Alignment," was inspected on December 16, 199 * Corrective Maintenance Procedure 1440-Y-3, " Scaffolding Construction / Inspection," was inspected on January 15, 199 Overall, the inspector found that individuals performing the circuit breaker maintenance (PMP E-28) were knowledgeable, maintenance procedure quality was good, and proper QA documentation existed for replacement parts. The inspector concluded that overall i

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performance of the above maintenance activities was satisfactor .2 Liquid Effluent Release with Total Station Flow Recorder Selpoint Low On December 5,1992, while returning the Dow recorder FR-146 (total station flow to the river) setpoint to normal following the release of the 'A' waste evaporator condensate storage tank (WECST) to the efnuent of the mechanical draft cooling tower, the licensee found that the setpoint was set at 9,000 gpm. The release permit required the setpoint to be 20,700 gpm. An examination of the flow recorder revealed that the indicated flow never dropped below 20,700 gpm during the release. The setpoint on FR-146 provides an alarm and interlock to terminate the release if dilution Doiv drops below the setpoint during the releas Plant Radiological l'ngineering calculated that if dilution flow had actually decreased to 9,000 gpm, the release would have been approximately 40% of the maximum permissible concentration for tritium, which was the limiting isotope for the releas The inspector reviewed the applicable Technical Specincations associated with the releas Technical Specification 3.21.1 requires FR-146 to be operable with its alarm / trip setpoint set to ensure that the limits of Technical Specification 3.22.1.1 are not exceeded. Technical Specification 3.22.1.1 limits the concentration of radioactive material released to unrestricted areas to the limits specified in 10 CFR 20, Appendix B, Table 11, Column 2. Technical Specification 3.21.1 further requires that the setpoints be determined in accordance with the Offsite Dose Calculation Manual (ODCM).

Technical SpeciGcation 3.21.l(a) states that with a radioactive liquid effluent monitoring instrument channel alarm / trip setpoint less conservative than required, immediately suspend the release of radioactive liquid efDuents monitored by the affected channel or declare the channel inoperable. This action statement could not be implemented because the release had been terminated prior to discovery of the error in the setpoint. Technical Specification 3.21.l(b), action statement 21 for inoperability of FR-146 states that radioactive releases via this pathway may continue, provided a flow rate is estimated at least once every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> during actual releases. FR-146 flow is recorded on the release permit at the start of the WECST release, after 1/4 complete, after 1/2 complete, after 3/4 complete, and after the release is complete. Since the relesse occurred over a 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> period, the FR-146 recorder readings were taken approximately every 2.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. Therefore, the licensee unintentionally met the Technical Specification action statement for 4-hour readings. - The inspector reviewed the completed release permit and 21,000 gpm was the lowest recorded value for FR-146 flo The Plant Review Group determined that this incident was not reportable because the licensee performed the action statement associated with FR-146 inoperability. Therefore, there was no operation or condition prohibited by the plant's Technical Specifications. The inspector agreed that this incident was not reportabl Licensee corrective actions include revising affected procedures to provide for independent verification of the setpoint by the Operations Department prior to the release. Radiological

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Engineering plans to change their release permit to present the FR-146 setpoint in mgpd rather than gpm so that the I&C technicians will not have to perform a conversion from the release permit value to the serpoint thumbwheel scale.

The inspector concluded that although the limiting condition for FR-146 operability was not met, the licenste complied with the associated action statement and, therefore, there was no Technical Speci0 cation violation. This incident is considered to be an isolated case and the licensee's corrective actions are adequate to prevent recurrence of a similar incident. (Closed) Violation (NC4, 50-289/5'2-01-01) Scaffolding Deficiencies This item concerned the failure of the Operations Department to inspect a scaffolding in the Auxiliary Building to ensure that scaffolding would not endanger safety related equipment.

This deficiency was one of five deficiencies noted in the inspection report. In the violation response the licensee acknowledged that the repetitive deficiencies did occur. The licensee also determined the deficiencies were the result of a breakdown in the controls and processes established for the proper use of scaffolding at Thil. The licensee reviewed Corrective Maintenance Procedure (Ch1P) 1440-Y-3, " Scaffolding Construction / Inspection," and determined that the proper procedural controls were in place but adherence to these controls did not occu The corrective actions the licensee has implemented include adding daily checks of scaffolding to the Auxiliary Operator (AO) logs so that scaffolding deficiencies can be discovered and corrected. The AOs have been trained to check to ensure that the inspection tag is in place and has the appropriate inspection signatures for each scaffolding erecte The AO also checks to ensure the scaffolding does not hinder operation of or access to components. In addition, the licensee has instructed cognizant personnel on the control and use of scaffoldin The inspector reviewed CMP 1440-Y-3 and agrees with the licensee that adequate procedural controls are in place to control scaffolding and that the cause of the scaffolding deficiencies was the failure to implement these controls. The inspector verified that cognizant personnel have received additional training on the control of scaffolding. During plant tours, the inspector has noted no additional scaffolding deficiencies since the violation was issued. The-inspector concluded that the licensee's corrective actions were adequate to prevent recurrence of similar incident .4 Operation of Fuel Handling Building Ventilation without the Effluent Radiation Monitor (URI, 50-289/92-22-02)

On December 12, 1992, the licensee performed Surveillance Procedure (SP) 1303-11.56,

" Fuel Handling Building Engineered Safety Feature (ESP) Air Treatment System Air Filter Efficiency Test," without the Fuel Handling Building effiuent radiation monitor, RM-A-14, .

in service. This test is performed once per refueling outage. Technical Specification 3.2 requires that the RM-A-14 noble gas activity monitor (or suitable equivalent), the iodine

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canridge, the particulate filter, the effluent system flow recorders, and the sampler flow rate monitor be operable during Fuel Handling Building ESF air treatment system operationc Due to the failure to properly follow and sign off the SP 1303-11.56 as written, the 'A' train of the ESF ventilation was operated for 5.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> with the RM-A-14 pump turned of The day-shift Shift Foreman was notified that the test supervisor needed to place the 'A' train of the ESF ventilation into service to support Surveillance Procedure (SP) 1303-11.56. The Shift Foreman instructed an Auxiliary Operator (AO) to place the 'A' train of the ESF ventilation system into service. The Shift Foreman did not specifically tell the AO to perform the task in accordance with OP 1104-15D, " Fuel Handling Building ESF Air Treatment System Operating Procedure." SP 1303-11.56, prerequisite 4.1, states that all prerequisites of Operating Procedure (OP) 1104-15D are to be observed. Operating Procedure 1104-15D, prerequisite 14, verifies that Rht-A-14 or suitable equivalent is in service. The Shift Foreman did not inform the Shift Supervisor that the system was running and did not address the Technical Specification actions associated with RM-A-14. The test supervisor did not sign off any of the 'A' train portion of the surveillance procedure, including these prerequisites, until after the completion of the 'A' train testing and the requirement to place RM-A-14 in service was misse The evening-shift Shift Supervisor was informed of the 'A' train ventilation testing during turnover. The evening-shift operating crew attempted to place Rhi-A-14 in service but did not complete this task because they could not obtain proper indication of which RM-A-14 filter was in service. The licensee later determined that cause of the improper indication was an inadequacy in OP 1105-8, " Radiation Monitoring System," which places RM-A-14 in service. The evening-shift Shift Supervisor consulted Technical Specification 3.1 concerning the Fuel Handling Building ESF ventilation and Technical Specification 3.2 concerning RM-A-14 and determined that since no fuel handling operations were in progress and the ventilation system was in a testing mode, no real requirement for RM-A-14 existe However, Technical Specification 3.21.2 states that RM-A-14 must be operable any time the ESF ventilation system is in operation. The licensee completed testing of the 'A' train ventilation on the evening-shift. The next day, the day-shift Shift Supervisor discovered that the ventilation had been operated without RM-A-14 in servic The inspector evaluated the safety significance of operating the Fuel Handling Building ESF ventilation without RM-A-14 in service. The purpose of RM-A-14 is to monitor the release of radioactive materials in gaseous effluents during actual or potential releases. RM-A-14 has a high and low range gas channel that reads out in the control room and via installed filter cartridges, particulate and iodine sample may be obtained. RM-A-14 has no automatic control or isolation functions. During the time the ventilation system was operated, no handling of irradiated fuel occurred. RM-A-13 was in operation during the period RM-A-14 was out of service. RM-A-13 is a movable atmospheric monitor located in the Fuel Handling Building that has iodine, particulate, and gaseous channels. RM-A'-13 meters and recorder have a local indication only. RM-A-13 could have been used to calculate the amount of any release that would have occurred during this period. Therefore, the safety significance of not placing RM-A-14 in service is considered minor, i

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The inspector reviewed the Technical Speci6 cation action statements associated with RM-A-14 inoperability. Technical Specification 3.21.2, Action 27, states that ef0uent releases may continue provided grab samples are taken at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and the initial samples are analyzed for gross activity within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Since the ventilation was only operated a total of 5.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />, the grab sample was not required. Initial samples were not taken and analyzed; however, the Technical Specification is silent on when during the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> period the initial sample must be taken. Technical Specincation 3.21.2, Action 31, states that effluent releases may continue via this pathway provided that within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after the channel has been declared inoperable, samples are continuously taken with auxiliary sampling 3 equipment. RM-A-13 is considered to be acceptable auxiliary sampling equipment. The g inspector determined that licensee unknowingly met the requirements of the RM-A-14 action statements and, therefore, no Technical SpeciGcations were violated and this incident was not reportable.

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The inspector questioned the licensee if a pre-test briefing was conducted. The inspector j found that although there were discussions among individual test participants, there was no g comprehensive briefing for all of test personne The licensee is preparing a Plant E<perience Report (PER) which will address the root cause of het incident and corrediva actions to prevent recurrence. The PER will also provide an assessment of the safety implications of the even The lack of preparation for the surveillance tests and the controls used during test performance have been noted weaknesses in the last SALP (50-289/90-99). These weaknesses were more prevalent during infrequently performed procedures. The inspector considered it a weakness that; the day-shift Shift Foreman and/or the test supervisor did not properly communicate to the AO the procedural requirements for placing the ventilation system in service; the evening-shift Shift Supervisor did not recognize Technical Speci0 cation 3.21.2 should have been entered for RM-A-14 inoperability; OP 1105-8 did not provide adequate instructions for placing RM-A-14 in service; and no pre-test briefing was conducted for this infrequently performed test. The inspector concluded that the licensee has initiated the proper review for this event. This issue will remain unresolved pending completion of the licensee's evaluation (50-289/92-22-02). SECURITY (71707)

The inspectors verified the implementation of the Physical Security Plan by verifying:

Protected Area and Vital Area barriers were well maintained and not compromised; isolation zones were clear; personnel and vehicles entering and packages being delivered to the Protected Area were properly searched and access control was in accordance with approved licensee procedures; persons granted access to the site were badged to indicate whether they have unescorted access or escorted authorization; security access controls to Vital Areas were !

being maintained and persons in Vital Areas were properly authorized; Security posts were l adequately staffed and equipped; and adequate illumination was maintaine l l

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8-The inspectors leviewed the upgrades to the secondary alarm station that were completed:

• during the inspection period. The inspector considered these upgrades were a very good ;

enhancement to plant security. The inspectors concluded that the Security Plan was being -

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properly' implemente .0 SAFETY ASSESSMENT / QUALITY YERIFICATION (40500,92702) Licensee Event Report (LER) In-Office Review-The inspector reviewed all TMI LERs th'at were submitted to the NRC Region I office in -

1992, to verify that the details of the events were clearly reportediincluding the accuracy of?

the description of cause and the adequacy _of the corrective action. The inspector determined -

whether further information was required from the licensee, whether the event should be'-

classified as an Abnormal Occurrence, whether the information involved 'with the event should be submitted to Licensing Boards, whether generic implications were-indicated, and

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whether the event warranted on-site followu LER 92-001-00 regarded an inadvertent emergency feedwater system actuatior, that occurred ~

on January 22,1992. The actuation occurred due to heat sink protection system modification 1 construction error that had gone undetected.until the actuation.

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LER 92-002-00 regarded a turbine / reactor trip on September 18,1992, caused by a trip of the ' A' train circulating water pumps. . The main cause of the trip was not having a?

procedure to defeat the circulating water system waterbox pressure switches.

E E - LER 97 003-00 regarded the reactor building atmospheric monitor being rendered inoperable

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due to the failure to properly return the monitor to service during a surveillance' procedure restoratio ~

- The NRC review of the above LERs is considered complete based on satisfactory in-officeL 4 N

review. The technical issues related to the LERs are discussed in detail in Inspection

, Reports 50-289/91-30,- 92-18 and, 92-2 ' . NRC MANAGEMENT MEETINGS AND OTIIER ACTIVITIES (30702)

p Routine Meetings

- At periodic intervals during this inspection, meetings were held with senior plant

- management to' discuss licensee activities and areas of concern to the inspectors. At they

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conclusion of the reporting period, the resident inspector staff conducted an exit meeting with . y L

licensee management summarizing inspectio'n activity and findings for this report period;JNo O proprietary information and no'information related to Unit-2 Post-Defueling Monitored , 4l g Storage was identified as being included in the report.

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